The country of origin of toilet paper

N359642 March 27, 2026 OT:RR:NC:N4:434 CATEGORY: Country of Origin Elise Shibles Sandler, Travis & Rosenberg, P. A. - Miami, FL 5835 Blue Lagoon Drive, Suite 200 Miami, FL 33126-2061 RE: The country of origin of toilet paper Dear Ms. Shibles: In your letter dated March 10, 2026, you requested a country of origin ruling on behalf of your client, Component Sourcing International, for the marking purpose. Photos and a detailed description of the manufacturing operations were provided for our review. The paper product under consideration is packages of “toilet tissue paper.” You indicate that it is made of white/kraft paper from virgin fiber; layer: 1-2; 13-14 grams per square meter/1 ply. Per your submission, the parent rolls of toilet paper stock are manufactured in Indonesia. These parent rolls of tissue paper measure in multiple widths from approximately 2750 mm to 2800 mm with a maximum roll diameter of approximately 2800 mm, are then sent to China, where the paper is unwound, embossed, rewound, and cut to size. The toilet paper is then subjected to quality control and packaged. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In China the toilet tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by unwinding, embossing, winding, cutting, and packaging. As support, we reference HQ W967997, dated October 5, 2006, in which the processes of printing, cutting and folding tissue paper in a second country did not result in a substantial transformation. Likewise, in HQ 557462, dated September 13, 1994, the operations of cutting and folding were found to be merely finishing operations, which, again, did not constitute a substantial transformation. The country of origin of the finished toilet paper for marking purpose is Indonesia. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Susana Li at susana.y.li@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division